selection and use of firefighting foams - fpa a

IB-06 V3 Selection and use of firefighting foams

1 Information Bulletin

Version 3 May 2020

Selection and use of firefighting foams

Information Bulletin

IB 06



Table of Contents

1 Purpose statement ................................................................................................................................................ 3

2 Audience ............................................................................................................................................................... 3

3 Abbreviations ........................................................................................................................................................ 3

4 Background ........................................................................................................................................................... 3

5 Factors impacting on selection and use ................................................................................................................ 4

5.1 Firefighting performance .................................................................................................................................. 4

5.2 Environmental impact ....................................................................................................................................... 5

5.3 System and equipment compatibility ............................................................................................................... 5

6 Environmental and firefighting performance indicators ...................................................................................... 6

6.1 Environmental performance indicators ............................................................................................................ 6

6.2 Firefighting performance indicators ................................................................................................................. 7

7 Environmental Regulations ................................................................................................................................... 8

7.1 NICNAS (National Industrial Chemicals Notification and Assessment Scheme) ............................................... 8

7.2 PFAS National Environmental Management Plan (NEMP) – EPA ..................................................................... 9

7.3 Queensland—Environmental Management of Firefighting Foam – Operational Policy (QLD Foam Policy) .... 9

7.4 South Australia—Environment Protection (Water Quality) Policy 2015 (SA WQ Policy) – Amendment

banning PFAS foam use – Implemented January 2018 ................................................................................... 10

7.5 USA .................................................................................................................................................................. 10

7.6 Canada............................................................................................................................................................. 10

8 Different types of firefighting foam .................................................................................................................... 10

8.1 Fluorinated firefighting foams (C8 and C6 Foams) ......................................................................................... 10

8.2 Fluorine-free firefighting foams (F3 foams) .................................................................................................... 12

9 Environmental Best Practice ............................................................................................................................... 13

9.1 Training and system testing and commissioning ............................................................................................ 13

9.2 Firewater effluent ........................................................................................................................................... 13

9.3 Remediation of PFAS contaminated soil and water ....................................................................................... 14

9.4 Cleaning/change out of existing legacy fluorinated foams ............................................................................. 15

10 Recommendations .............................................................................................................................................. 15

11 References........................................................................................................................................................... 16

Appendix A – Abbreviations ............................................................................................................................................ 17

Appendix B – Health concerns and phase out of legacy C8 foams and the use of replacement C6 foams ................... 17



1 Purpose statement

The purpose of this document is to increase awareness

of the issues surrounding the selection and use of

firefighting foams based on their:

Firefighting performance;

Environmental impact; and

System and equipment compatibility.

This Information Bulletin also provides information on

the different types of firefighting foams, suggestions

for environmental best practice, as well as general

recommendations for the selection and use of

firefighting foams.

NOTE: The content of this Information Bulletin is informed by the real world experiences of our members as well as significant local and international research in this area, see Section 11 “References”.

2 Audience

This Information Bulletin is intended for:

(i) FPA Australia members;

(ii) Users of firefighting foams, including owners of facilities protected by foam systems and response agencies who use firefighting foam; and

(iii) Other stakeholders involved in the selection and use of firefighting foam, including manufacturers, suppliers, installers and maintainers of fire protection systems and equipment that use firefighting foam.

3 Abbreviations

Abbreviations are used extensively in this Information

Bulletin to make the document easier to read.

Refer to Appendix A for a list of these abbreviations.

4 Background

Firefighting foam is an effective suppression agent for

preventing, extinguishing or controlling fires involving

flammable liquids (Class B fuels). Its use can

significantly reduce the risk to life, property,

environment and business disruption from such fires.

Also, in addition to limiting the growth and impacts of

a fire, use of these foams also reduces the amount of

noxious and harmful breakdown products—including

known carcinogens—released by the fires on which

they are used.

Firefighting foam is used in fixed and portable fire

extinguishing systems as well as fire brigade apparatus.

Firefighting foam is produced by mixing foam

concentrate with water to produce foam solution. This

solution can either be applied:

Non-aspirated (through water nozzles, sprinklers or deluge nozzles, provided the foam is suitable for application through these devices); or

Aspirated (when the foam solution is mixed with air through dedicated foam making devices; such as, a foam branch pipe, top pourer, foam cannon, foam sprinkler or high expansion generator).

The application of firefighting foam to liquid fuel fires

suppresses the release of flammable vapours,

separates flames from the fuel, blocks the supply of

oxygen to the fuel and cools the fuel surface.

The environmental acceptability of different types of

firefighting foam has been a topic of increasing global

discussion in recent years, with particular focus on the

properties of fluorinated versus fluorine free foams (F3

foams). Whilst a vast amount of environmental

information is now available in the public domain,

FPA Australia is concerned that much of this

information focusses on environmental issues in

isolation of other key factors such as firefighting

performance, firefighter safety and system

compatibility.

FPA Australia recognises that fire protection products

and practices must be environmentally responsible. In

fact, protecting the environment is a fundamental part

of the Association’s Vision. However, FPA Australia

contends that acceptable fire life safety, fire protection

and environmental outcomes cannot be achieved by

consideration of any single performance characteristic.

All the characteristics and properties of a product or



system must be considered holistically to reach a well-

informed view as to which product or system is best

suited for a particular application. FPA Australia

contends that the decision to select and use a

particular type of foam should only be made after

careful consideration of a range of factors, including:


Protection of personnel (both firefighters and the community);

Potential adverse environmental impacts;

Compatibility with the fixed or portable fire systems in which it is to be used;

Compatibility with existing foam concentrate in storage;

Compatibility with materials (e.g. potential tank/pipework corrosion and seal materials);

Compatibility with existing proportioning equipment; and

Cost.

This document is intended to provide a balanced

overview of the key issues which impact on the

selection and use of firefighting foam. Only by careful

consideration of all these key criteria can foam users

make an informed decision as to which type of foam is

most suitable for their current and future needs.

5 Factors impacting on selection and use

Three main factors must be considered when assessing

the selection and use of firefighting foam:


Environmental impact; and

System/equipment compatibility.

5.1 Firefighting performance

Firefighting foam is used to prevent, control and

extinguish fires. The firefighting effectiveness of a

foam must be a prime consideration for its selection

and use.

To be effective, a firefighting foam must:

Rapidly spread over the fuel surface;

Cool the fuel surface;

Resist mixing with the fuel;

In the case of polar solvent (water miscible) fuels, resist attack from or breakdown by the fuel;

Suppress the release of flammable vapours;

Resist breakdown due to radiant heat; and

Provide protection from re-ignition and flash-back.

A high level of firefighting performance is essential to

protect life, property and the environment. High level

firefighting performance facilitates:

Rapid fire extinguishment;

Reduced potential for fire spread;

Reduced release of toxic products of combustion;

Reduced usage of water and foam;

Reduced risk to the life safety of responding firefighters and the community; and

Reduced volume of firewater effluent (foam and products of combustion).

It is essential that the firefighting performance of any

foam being considered for use—irrespective of

whether it is a fluorinated or fluorine free foam—is

independently tested and certified to relevant and

recognised standards.

Poor firefighting performance will result in fires being

more difficult to extinguish and burning longer. This, in

turn, will result in an increased release of toxic and

carcinogenic products of combustion into the

environment. Contaminates in firewater runoff have

a direct adverse impact on the environment, so

minimising the quantity of water used to extinguish a

fire is also essential to minimising environmental

impacts. Additionally, use of a foam with inferior

firefighting performance can adversely affect the

safety of firefighters and the wider community.

There are a range of firefighting performance test

standards which, depending upon the intended



application, can be used to demonstrate the suitability

of a foam for a particular application. Some commonly

used test standards are listed in Clause 6.2.

Demonstrated evidence of firefighting performance—

to the relevant test standard, using representative

fuels and operating conditions—is essential in selecting

the most suitable firefighting foam for a particular

application.

5.2 Environmental impact

FPA Australia supports efforts to reduce the adverse

impacts that fire and firefighting activities have on the

environment. Appropriate selection and use of

firefighting foams is important as some firefighting

foams do have a greater environmental impact than

others by virtue of their chemical composition.

It must be clearly understood, however, that all

firefighting foams and firewater runoff have the

potential to pollute the environment. Short-term

effects can be expressed in terms of acute toxicity and

Biochemical Oxygen Demand (BOD). A comparison of

foams published in 2006 by the Fire Fighting Foam

Coalition (FFFC) indicated that, in terms of acute

effects, F3 foam concentrates fell into the ‘Slightly

Toxic’ category while fluorinated foam concentrates

were categorised as ‘Relatively Harmless’.

Regardless of the type of firefighting foam used, it is

also extremely important to consider the

environmental impact from the combustion products

of the fire itself. Whilst it is difficult to quantify the

environmental impact of an individual fire, it is clear

that extinguishing a fire as quickly as possible will

reduce adverse environmental effects resulting directly

from the fire. Using a foam with superior firefighting

performance can minimise the amount of foam and

water required and will result in less firewater effluent

whilst also reducing the quantity of combustion

products released, potentially reducing adverse

environmental impacts.

Failure to adequately consider the firefighting

performance of a foam may result in selection of a

foam that is ineffective for the intended application,

increasing the adverse environmental impacts from a

fire incident whilst also increasing the risk to life safety

of both firefighters and the community.

For more information on environmental impact, see

Section 6.

5.3 System and equipment compatibility

Fire testing protocols for firefighting foams evaluate

performance under representative conditions for the

application in question, including, extremes of ambient

temperature, the fuel type and the aspiration ratio

available from discharge devices.

Use of a firefighting foam which has not passed the fire

testing protocols applicable to the fire protection

system or equipment that it is to be used in may

increase the risk to life, property and the environment

from a fire incident. Its use may also have serious

implications for product/system approvals and

insurance cover.

It is important to remember that firefighting foams

form only one part of a system and a decision to change

the type of foam used should not be made without

considering the impact of that change on the complete

system.

Before making a decision to change the type of

firefighting foam used, consultation with key fire

protection stakeholders, especially foam system

designers and manufacturers, is essential to ensure the

performance of the system will not be adversely

affected.

Important factors that must be considered include:

Viscosity of the foam concentrate (Newtonian and thixotropic);

Suitability for use with existing proportioning hardware;

Homogeneous mixing of concentrate with water;

Compatibility with materials in the system (e.g. plastic, rubber seals, metals, etc.);

Stability of foam concentrate or pre-mix solution (separation, stratification, sedimentation);



Suitability for use on the flammable liquids in question;

Suitability of application method (aspirated, non-aspirated, forceful, gentle);

Extremes of ambient temperature that may be encountered in an incident;

Suitability of the expansion ratios produced by existing equipment for effective firefighting performance; and

Suitability of the application rates produced by existing equipment for effective firefighting performance.

6 Environmental and firefighting performance indicators

A range of methods exist to assess the environmental

impact and firefighting performance of firefighting

foams. Some of these are detailed below.

6.1 Environmental performance indicators

Scientific measures used to assess the impact of

chemicals include Biochemical Oxygen Demand (BOD),

Chemical Oxygen Demand (COD) and aquatic toxicity.

These factors have an influence on the likely short-

term impacts of the chemical. Guidance values that can

be used to quantify the biodegradation of a chemical’s

environmental impacts are provided below:

Short-term: ≤ 40% within 7 days

Long-term: ≥ 65% within 28 days

BOD/COD profiling identifies the biodegradability and

de-oxygenating characteristics of chemicals in the

environment. Chemicals that biodegrade rapidly can

suffocate organisms by consuming available oxygen, as

can larger quantities of high BOD chemicals in the

environment.

Other factors, as detailed below, are also used to

establish whether a chemical has other environmental

or health effects that necessitate high levels of concern

and/or control.

6.1.1 UN Stockholm Convention

The Stockholm Convention on Persistent Organic

Pollutants (POP), an international treaty signed in 2001

and effective from May 2004, aims to eliminate or

restrict the production and use of POPs. Australia is

one of 179 parties who are signatories to this

convention. Australia ratified the Convention on

20 May 2004 and became a party to it on

18 August 2004.

Perfluorooctanyl Sulfonate (PFOS) was added as a POP

to the Convention in 2009 (see Clause B1).

The Persistent Organic Pollutants Review Committee

(POPRC) established by the Convention developed a

procedure for the consideration of individual substances.

To qualify as a POP, a substance must meet all four of the

following criteria:

(P) Persistence in the environment

(i) Evidence that the half-life of the chemical in water is greater than two months, that its half-life in soil is greater than six months, or that its half-life in sediment is greater than six months; or

(ii) Evidence that the chemical is otherwise sufficiently persistent to justify its consideration within the scope of the Convention.

(B) Bio-accumulation

(i) Evidence that the bio-concentration factor or bio-accumulation factor in aquatic species for the chemical is greater than 5000 or, in the absence of such data, that the octanol-water coefficient (KOW) is greater than 5; or

(ii) Evidence that a chemical presents other reasons for concern, such as high bio-accumulation in other species, high toxicity or eco-toxicity; or

(iii) Monitoring data in biota indicating that the bio-accumulation potential of the chemical is sufficient to justify its consideration within the scope of the Convention.



(T) Toxicity

(i) Evidence of toxicity or eco-toxicity data that indicates the potential for damage to human health or to the environment.

(LRET) Potential for Long-Range Environmental Transport

(i) Measured levels of the chemical in locations distant from the sources of its release that are of potential concern; or

(ii) Monitoring data, modelling or environmental fate properties showing that LRET of the chemical, with the potential for transfer to a receiving environment, may have occurred via air, water or a migratory species.

If a substance meets each of the above criteria, risk

profiling is used to evaluate whether, as a result of its

LRET, a substance is likely to lead to significant adverse

human health and/or environmental effects and

therefore warrants global action. If global action is

warranted, a risk management evaluation is

undertaken reflecting socio-economic considerations

associated with possible control measures and the

substance is listed under the appropriate annex of the

convention. Annexes include:

Annex A – Elimination;

Annex B – Restriction; and

Annex C – Unintentional production.

The legacy C8 foam fluorosurfactant PFOS became a listed POP in 2009. Perfluorooctanoic Acid (PFOA) has been accepted for listing as a POP by the Stockholm Convention POPRC and is expected to be added, with Perfluorohexane Sulfonate (PFHxS) likely to follow.

In May 2019, the Conference of the Parties (COP-9) accepted the revision that the Stockholm Convention “Encourages Parties and others to use alternatives to PFOA, its salts and PFOA-related compounds, where available, feasible and efficient, while considering that fluorine-based fire-fighting foams could have negative environmental, human health and socioeconomic impacts due to their persistency and mobility.”

The Committee recognised that some time may be needed for a transition from long-chain C8 PFAS to alternatives.

6.2 Firefighting performance indicators

As previously highlighted, it is important to consider

the firefighting performance and system compatibility

of any foam when considering changing to a different

foam from that currently used.

There are a number of local and international

standards that are used to rate the firefighting

performance of foam. These include, but are not

limited to the latest versions of:

(i) Australian Standards

AS/NZS 1850, Portable fire extinguishers – Classification, rating and performance testing;

AS 5062, Fire protection for mobile and transportable equipment; and

DEF(AUST) 5706, Foam Liquid Fire Extinguishing, 3 percent and 6 percent concentrate.

(ii) International Standards

EN 1568, Fire Extinguishing Media – Foam Concentrates (Parts 1, 2, 3 & 4);

EN 13565, Fixed Firefighting Systems – Foam Systems (Parts 1 & 2);

International Civil Aviation Organisation (ICAO) Fire Test Method, Doc 9137 — Airport Services Manual, Part 1 — Rescue and Fire Fighting;

NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam;

UL 162, Standard for Safety for Foam Equipment and Liquid Concentrates;

Mil-PRF-24385F(SH) Amendment 2, Fire Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, for Fresh and Sea Water; and

Factory Mutual 5130 (foam enhanced sprinklers).

In addition to these test standards, there are a number

of listing or product certification schemes that provide

independent evaluation of fire protection products,

including firefighting foams. Evidence of suitability

from such listing bodies should be sought to confirm



the firefighting performance of a foam on the fuels to

be protected; with the type of equipment to be used;

and, under the conditions likely to be experienced on

the site. When considering the use of product that has

been listed or certified, it is important to check the

basis for listing or certification and that this includes

testing to a standard relevant for the intended

application.

The performance parameters identified as a result of

testing to these standards will typically include:

Time to achieve extinguishment;

Burn-back resistance; and

Speed of knockdown and vapour control.

Recognising that some current international standards

do not detail recommended application rates and

operational duration for modern fluorine free (F3)

foams, NFPA and UL in the USA have both started

testing programs to determine effective recommended

application rates for F3 foams in comparison to AFFFs.

Recent NFPA research into the effectiveness of fluorine

free firefighting foams found that in comparison to the

C6 AR-AFFF foam baseline used (and noting some

variability in the capability of the 5 F3 foams tested) all

F3 foams tested required much higher application rates

and density to achieve similar results to C6. The F3

foams also required higher expansion ratios to

enhance their performance.

This research also found that heptane, which works as

an ‘equivalent’ to gasoline for C6 foams, does not work

as an ‘equivalent’ to gasoline for F3 foams. The reasons

for this were identified in a previous US Naval Research

Laboratory (NRL) that identified aromatic components

within gasoline as the source of the increased difficulty

in gasoline fire suppression compared to heptane fire

suppression using F3 foams. This NRL research also

recommended a more appropriate test fuel for F3

foams so that, like C6 foams, one fuel can be used in

testing and cover multiple fuels/applications.

As such, while the performance of F3 foams has

improved, further testing is demonstrating specific

factors that need to be considered in standards relating

to firefighting foams and in selecting F3 foams.

Also, it is important to note that these factors and more

need to be considered in selecting any firefighting

foam—whether a C6 or F3 foam—to be used in a new

or existing system. In particular, no foam should be

considered a “drop-in” replacement in an existing

system; its suitability must be confirmed.

Selection needs to consider all of the system and

equipment compatibility factors listed in Clause 5.3,

above, and evidence of its suitability should be

demonstrated by testing to a relevant standard, or

listing or certification that includes testing to a relevant

standard.

Also, given the ongoing evolution of firefighting foams

(particularly F3 foams), consideration should also be

given to any new research (like the NFPA and NRL

research above) as well as the real-life performance of

specific foams in major fire incidents, as valuable

additional indicators of potential firefighting

performance and environmental behaviour.

7 Environmental Regulations

Regulation and restriction of undesirable legacy C8 PFAS

chemicals is increasing around the world in response to

legacy site contamination of soils, groundwater, human

blood levels, food and drinking water where there was

intensive use at specific locations for decades (e.g.

airports, defence sites and fire brigade training areas).

Specific high profile site contamination has led to a legacy

requiring clean up and management, but it is believed to

be restricted to legacy C8 PFAS (e.g. PFOS, PFOA, PFHxS).

7.1 NICNAS (National Industrial Chemicals Notification and Assessment Scheme)

NICNAS, a branch of the Australian Government’s

Department of Health, helps protect the Australian

people and the environment by assessing the risks of

industrial chemicals and providing information to

promote their safe use.

It makes recommendations about chemicals to other

government agencies responsible for the regulation of

industrial chemicals, collects data on the use of

industrial chemicals in Australia and ensures Australia



meets its obligations under international agreements

about chemicals.

NICNAS advice includes:

The Inventory Multi-tiered Assessment and Prioritisation (IMAP) Environmental Tier II Risk Assessment for C6 PFAS, which sets its status as Persistent, not Bio-accumulative, not Toxic; and

The IMAP Human Health Tier II Risk Assessment’s occupational and public health risk characterisations for C6 PFAS, which concluded “C6 chemicals are not considered to pose an unreasonable risk to workers health” and “the public risk from direct use of these chemicals is not considered to be unreasonable”.

7.2 PFAS National Environmental Management Plan (NEMP) – EPA

The PFAS NEMP was developed by Australian State and

Territory Environmental Protection Authorities (EPA) &

the New Zealand EPA and was implemented in

February 2018. It includes extensive guidance notes

designed to help governments, industry and the

community identify, monitor and respond to PFAS

contamination.

The NEMP includes the following:

All PFAS (C8 and C6) to be covered;

Requirements for PFAS monitoring and assessment, plus site evaluation and prioritisation;

Defined measurement techniques for PFAS and environmental levels indicating a need for action;

Guidance on how to deal with sites contaminated with PFAS: waste, transport and treatment, with information sharing across Australia;

Requirements for updating of the NEMP as an evolving document to incorporate emerging new data;

Requirements for evaluation of the NEMP’s effectiveness, and future research towards future revisions;

Definition of key trigger values for soil investigation, biota guideline values, landfill acceptance and health based drinking/recreational water values; and

Requirements for collection, separation, treatment, destruction of all PFAS.

7.3 Queensland—Environmental Management of Firefighting Foam – Operational Policy (QLD Foam Policy)

The first PFAS regulation in Australia, this policy was

implemented in Queensland by the Department of

Environment and Science in July 2016.

The QLD Foam Policy requires:

Immediate removal of PFOS legacy foams from service;

Containment and control measures for all PFAS foams so none enters the environment;

Phase out of fluorinated firefighting foam where primarily the perfluorinated part of the carbon chain is longer than or equal to 7 carbon atoms (C8 foams) within 3 years;

Preference for F3 foam use wherever possible, but acceptance where this can be demonstrated not possible that C6 foams with a purity of >99.5% could be used providing there is complete collection and containment of all foam solution, firewater runoff and wastes in impervious dikes, with proper and safe disposal. This includes accidental spills and the testing/maintenance of fixed and mobile equipment;

High temperature (>1,100oC) disposal of all fluorinated organic wastes (including firewater runoff);

Containment of non-persistent F3 foam wastes, wherever possible, using all reasonable and practical measures to minimise environmental harm;

A 10 parts per million (ppm or mg/L) limit of PFOS/PFHxS residual contamination in replacement firefighting foam stock;

A 50 ppm limit of PFOA, precursors and higher homologues (≥ C7) contamination in replacement foam stock; and



Full compliance required of all foam users implementing F3 foams by July 2019 (extension by negotiation and documented progress, if necessary for major industries).

7.4 South Australia—Environment Protection (Water Quality) Policy 2015 (SA WQ Policy) – Amendment banning PFAS foam use – Implemented January 2018

This policy covers all firefighting foam uses from

portable extinguishers to fire trucks and fixed foam

systems in South Australia.

The SA WQ Policy includes:

A ban on the use of all fluorinated firefighting foams for all applications with a timeframe of two years for compliance for all non-handheld applications by January 2020.

This ban applies to hand-held applications (portable extinguishers) upon re-charge or re-fill or within two years of commencement of the policy, whichever is earlier;

Provisions to address PFAS contamination in existing equipment;

Certification of fluorine concentrations in foam to be provided by suppliers;

That EPA SA may consider an exemption application by demonstrating assessment of actions already taken and proposed to be taken plus a justification why F3 foams cannot currently be used at the site.

7.5 USA

A number of States in the USA are passing or considering

legislation to restrict the use of PFAS foams, particularly

for training purposes (where most usage occurs), but

allowing continued use of PFAS based foams for major

hazard facilities (e.g. California, Colorado, New

Hampshire, New York, Virginia and Washington).

The National Defense Authorization Act also provides

restrictions from 2024.

7.6 Canada

An exemption has been made which allows the use of

fluorine free foams at Canadian airport.

8 Different types of firefighting foam

Firefighting foams can be broken into two broad

categories:

Foams that contain fluorinated surfactants; and

Foams that are fluorine free.

However, there are also individual foam types within

these two broad categories.

Commonly used firefighting foam types are better

known by the following terms:

Fluorinated Foams

o AFFF—Aqueous Film Forming Foam

o AR-AFFF—Alcohol Resistant Aqueous Film Forming Foam

o FP—Fluoro-Protein Foam

o FFFP—Film Forming Fluoro-Protein Foam

o AR-FFFP—Alcohol Resistant Film Forming Fluoro-Protein Foam

Fluorine Free Foams

o F3—Fluorine Free Foam

o AR-F3—Alcohol Resistant Fluorine Free Foam

Note: High-expansion, protein, Class A and most training foams are, and always have been, fluorine free.

8.1 Fluorinated firefighting foams (C8 and C6 Foams)

8.1.1 Overview

Historically, fluorinated firefighting foams include

small quantities of perfluorinated and polyfluorinated



compounds (PFCs) or Per- and Poly-fluoroalkyl

Substances (PFAS), as they are more commonly called.

Perfluorooctanyl sulfonate (PFOS) and

perfluorooctanoic acid (PFOA) are two of the most

common PFAS-based products derived from a range of

precursors which were contained in older legacy C8

foams.

C8 foams have good firefighting performance but have

Persistent (P), Bio-accumulative (B), Toxic (T) and

Long-Range Environmental Transport (LRET)

characteristics, all of which are undesirable and have a

significant negative environmental effect and a

potential to harm human health.

Note: C8 foams—dependant on the specific formulation—may contain substances such as PFOS, PFHxS, PFOA and PFOA precursors.

C6 foams may contain trace levels of PFOA, which are

unavoidably produced by the manufacturing process,

but these foams are acceptable under the US EPA PFOA

Stewardship program and the Registration, Evaluation,

Authorisation and Restriction of Chemicals (REACH)

Regulation (EU) 2017/1000, see Clauses 8.1.2 and

8.1.3.

C6 foams are persistent but are neither

bio-accumulative, nor toxic and are of low concern to

human health and the environment.

Further detail on health concerns and the phase out of

legacy C8 foams and replacement C6 foams is provided

in Appendix B.

8.1.2 US EPA PFOA Stewardship Program

The United States Environmental Protection Agency

(US EPA) Voluntary PFOA Stewardship Program (2006-

2015) aimed to eliminate PFOA content by 2015 from

the surfactants manufacturing processes, products and

waste streams by transitioning from C8 surfactants to

environmentally more benign C6 surfactants. US EPA

reports confirm this was achieved.

Note: For more information on the US EPA PFOA Stewardship Program, see https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/and-polyfluoroalkyl-substances-pfass-under-tsca#tab-3.

8.1.3 REACH Regulation (EU) 2017/1000

Foam manufactured or supplied in Europe must

comply with the REACH Regulation (EU) 2017/1000.

This Regulation permits C6 foams to include up to:

25 parts per billion (ppb or µg/L) of PFOA including its salts, or

1,000 ppb for one or a combination of PFOA-related substances.

Firefighting foams already in use are exempted from

this impurity restriction, so C8 foams purchased before

July 2020, could still be used until their expiry date and

be compliant with this European Union (EU)

Regulation. This Regulation has a 3 year transition

period, becoming effective from July 2020 (i.e.

completed by July 2023).

Note: For more information on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation (EU) 2017/1000, see https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R1000&from=EN.

8.1.4 Summary of fluorinated firefighting foams (C8 and C6 foams)

Fluorinated firefighting foams should not be grouped

as a single class in terms of their environmental

properties. C6 foams compliant with the US EPA PFOA

Stewardship Program and REACH Regulation (EU)

2017/1000 have distinctly different environmental and

human health characteristics to C8 foams that contain

PFOS or PFOA. As such, US EPA PFOA Stewardship

Program and REACH Regulation (EU) 2017/1000

compliant foams should not be subject to the same

level of restriction or environmental controls as those

imposed on legacy C8 foams.

https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/and-polyfluoroalkyl-substances-pfass-under-tsca#tab-3



https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R1000&from=EN





Further detail on health concerns and the phase out of

legacy C8 foams and replacement C6 foams is provided

in Appendix B.

8.2 Fluorine-free firefighting foams (F3 foams)

8.2.1 Overview

In response to the environmental concerns with PFOS

and PFOA fluorinated foams and as a result of

European and US reforms, F3 foam technology has

advanced in recent years and modern F3 foams are

available in both the Australian and international

markets.

F3 foams do not contain persistent fluoro-surfactants

and play an important role in fire protection and

training. However, as a general rule, they do not provide

the same level of firefighting performance as C8 foams

or C6 foams. Typically, F3 foams do not provide the

same fuel shedding, film forming characteristics, vapour

sealing or burnback resistance, which can be vitally

important to rapid extinguishment of fires in some

applications. These properties are particularly important

in industrial and petrochemical applications as well as

incidents where the foam is applied forcefully, as is often

inevitable in emergency incidents.

However, it must be noted that F3 foams are available

which have been certified to test standards including

UL 162, ULC, FM, ICAO, EN1568, IMO and LASTFIRE. As

is the case with all foams, users should verify that the

foam being considered for use has been independently

tested and certified to a standard relevant to the

intended application and are proven effective when

applied on the applicable fuels, at the extremes of

ambient temperatures and at the expected expansion

ratios and application rates expected from the

discharge devices used in the system. Any change in

foam type should not compromise the designed fire life

safety and critical infrastructure protections required

and provided by a foam based fire protection system.

While F3 foams are typically 100% biodegradable, and

are therefore not persistent in the environment, it

should be noted that the short-term environmental

impacts of many F3 foams have been shown to be an

order of magnitude higher in short-term aquatic

toxicity than C6 foams. Evidence suggests, when

unsuited to the application, they are slower to

extinguish volatile fuels, so more foam is likely to be

used, increasing BOD issues. These factors combined

could cause more short-term adverse impacts on fish

and other aquatic organisms, particularly in small or

isolated water bodies. It is therefore important to

remember that all foams pollute regardless of the type

of foam being used. As such, their use should be

minimised and the used foam solution and firewater

runoff collected and managed to reduce

environmental impacts.

A huge amount of investment and resources are being

directed to improve the performance of F3 foams by

organisations such as the FAA, US Research Naval

Laboratory, NFPA and UL.

FPA Australia supports the use of more

environmentally responsible foam formulations,

however, firefighting foams must only be used in

applications where they provide acceptable levels of

fire life safety and firefighting performance

demonstrated through a risk based assessment of

realistic worst case incident scenarios.

Historically, there have been a number of important

applications for which F3 have not been suitable;

(i) Portable fire extinguishers;

(ii) Non-aspirated pre-engineered foam/water spray systems used to protect large mining machines; and

(iii) Forceful application onto volatile fuels in depth (e.g. storage tanks and associated bunded areas).

Note: F3 foams are now used and approved for use in (i) Portable fire extinguishers and (ii) Non-aspirated pre-engineered foam/water spray systems used to protect large mining machines.

In Australia, the use of foam in application (i) requires

the portable fire extinguisher to pass the specific fire

test protocols detailed in AS/NZS 1850, Portable fire



extinguishers – Classification, rating and performance

testing.

The use of foam in application (ii) above, requires the

system to pass specific fire test protocols detailed in

AS 5062 Fire protection for mobile and transportable

equipment.

It is important to note that the 2016 edition of AS 5062

includes a number of new test requirements. These

include a 90 day agent (pre-mix) stability test and fire

testing using cylinders filled at least 30 days prior to

testing. All systems will need to be tested to these new

requirements in the future, whether fluorinated or

fluorine free, to claim compliance to AS 5062:2016.

FPA Australia is aware of systems using F3 foam that

have been tested to these latest requirements.

8.2.2 Summary of fluorine free foams (F3 foams)

As with C8 and C6 foams, F3 foams should not be

grouped as a single class in terms of their

environmental properties or performance. Some F3

foams have better firefighting and environmental

performance than others, and just like C6 foams,

evidence of suitability for adequate fire life safety and

fire protection of the application in question must be

sought before a commitment is made to use a specific

F3 foam.

9 Environmental Best Practice

The following outlines FPA Australia’s recommended

environmental best practice for use of firefighting

foams.

9.1 Training and system testing and commissioning

Training of personnel in the use, testing and

commissioning of fire protection systems is essential to

ensure the fire preparedness of a facility. However,

such activities should be undertaken in an

environmentally responsible manner.

To minimise the potential for firefighting foam to enter

the environment, FPA Australia recommends the

following measures be implemented to facilitate

training and system testing and commissioning:

Use training foams or other surrogate liquids that do not contain fluoro-surfactants for training, system testing and commissioning purposes, wherever possible;

Develop test and commissioning methods for foam proportioning systems which do not discharge foam to the environment;

Where the discharge of foam cannot be eliminated, ensure it is contained for appropriate collection/treatment/disposal in accordance with the requirements of the local regulatory authorities.

If containment is not possible, then training, testing and commissioning should only be carried out with a surrogate liquid that is neither persistent, nor bio-accumulative, nor toxic and without known potential human health impacts. Comparative proportioning rates using water only against the specific foam type could be considered, if sufficient reliable comparative data is available; and

New system designs or system upgrades should incorporate the facilities to allow testing and commissioning of the proportioning system without the need to discharge foam. This may be achieved by comparative flow meters (assuming similar viscosities of foam to water), incorporating a test return line to the bulk foam storage tank or alternatively diverting foam or a surrogate liquid to a dedicated test tank from which it can be recovered for re-use, or disposal in accordance with the requirements of the environmental regulatory authorities.

9.2 Firewater effluent

Firewater effluent or runoff contains many potentially

harmful chemicals and will possibly include PFAS;

unburnt hydrocarbon or polar solvent fuels; products

of combustion (potentially including Volatile Organic

Compounds (VOC) and Polycyclic Aromatic

Hydrocarbons (PAH), some of which are known

carcinogens); particulates; surfactants; water-soluble

polymers; hydrolysed proteins; organic matter;

suspended and dissolved solids; co-solvents;



anti-freezing agents; biocides; pathogens; and, other

compounds.

It is likely to also be contaminated with PFAS from a

wide range of consumer sources, including pre-existing

contamination of soil, water and other infrastructure,

even when F3 foams are used. Pre-existing PFAS

contamination is highly likely to exist on many

industrial sites.

For these reasons, all firewater effluent is potentially

hazardous and it is therefore vitally important that it be

contained as far as possible, regardless of whether C8,

C6 or F3 foam has been used or not.

This contained firewater effluent/runoff should then

be tested for contamination levels before

remediation/treatment or disposal in accordance with

the requirements of local environmental regulatory

authorities.

9.3 Remediation of PFAS contaminated soil and water

Considerable research work has been undertaken

recently into effective remediation options for soil and

water contaminated with C8 and C6 PFAS, particularly

PFOS/PFHxS and PFOA. An increasing number of viable

technologies are becoming commercially available.

Some of these technologies for adsorption, separation

and concentration of PFAS include:

Granular activated carbon (GAC) (effective predominantly for C8 PFAS);

Modified clays & bio-absorbent granules;

Ion exchange resins (IX);

Ozone fractionation with catalysed reagent addition (OCRA);

Membrane filtration including reverse osmosis (RO) and nano-filtration (NF);

Electrocoagulation; and

Reed bed filtration.

A number of well-documented commercially available case studies have been completed removing PFAS to non-detect levels.

Effective PFAS breakdown/destruction technologies include:

Electrochemical oxidation;

Cement kiln destruction*;

Plasma arc incineration/thermal destruction*;

Thermal desorption;

Sonic destruction;

Heated persulphate oxidation; and

Fungal degradation.

*Cement kiln destruction, plasma arc incineration and

thermal desorption are available in Australia. The other

technologies are yet to be commercially available in

Australia. For information on destruction options in your

local region, FPA Australia recommends you contact the local

environmental regulatory authority.

More recent additional technologies being explored,

and which show promise at laboratory and pilot scale,

include the following:

Photocatalysis—uses silicon, carbon and iron catalysts and short wavelengths (<200 nm) of UV light to degrade PFAS.

Note, it seems to be sensitive to pH and require longer exposure times for shorter chain PFAS substances.

Carbon nanotubes and filters—increase the surface area for PFAS adsorption, increasing effectiveness of short-chain capture and extending life and efficiency of filters.

Advanced electrochemical oxidation—creates free radicals and has also been shown to be effective, as has advanced reduction using nano zero-valent iron.

Colloidal activated carbon—has shown effective results in case studies providing soil barriers to curtail PFAS plume movements.

Ionic Fluorogels—leverage a synergistic combination of fluorophilic sequestration and targeted ion exchange to generate high performing and selective gels for PFAS remediation.

It has been shown to be highly effective at adsorbing PFAS substances (both long and



short-chains, including C4) from waste water treatment plant effluent.

These gels can also be regenerated to provide increased operational efficiency.

These technologies could also potentially be effective

methods of treating firewater runoff and fire training

ground effluent if they are proven to perform and

become commercially available.

9.4 Cleaning/change out of existing legacy fluorinated foams

FPA Australia recommends the following process when

cleaning foam tanks or changing out existing C8 foams:

1. Decant existing C8 foam into suitable storage containers, which are also bunded and clearly marked for incineration/destruction.

2. Thoroughly flush system with water and collect effluent in suitable storage containers/tankers, identifying contents. The use of hot water may facilitate cleaning.

Note: Changing from a foam containing PFOS or PFOA to a US EPA PFOA Stewardship compliant C6 foam, a REACH Regulation (EU) 2017/1000 compliant C6 foam or an F3 foam will require thorough washing of the tank and concentrate sections of pipework (including proportioners) until no frothing is visible. It also requires collection, remediation and safe disposal of all effluent from this washing process.

It is recommended a sample of the “clean” effluent be tested by a NATA accredited laboratory for traces of PFOS/PFHxS/PFOA to determine a baseline level of contamination for future reference and to confirm the storage is essentially “PFOS, PFHxS and PFOA free” down to the levels specified in the Queensland Policy, see Clause 7.3.

To avoid the possibility of contamination, the tank should not be filled with the replacement foam until the results of this testing are available and confirm sufficiently low levels acceptable to the local environmental regulator.

3. Using suitable remediation technologies, flushed foam solution and effluent should be treated to concentrate the PFAS into as small a volume as practical and should be held

separately and labelled prior to disposal/destruction.

4. Analyse clean water for residual PFAS levels, before any release for re-use to the sewer/environment to ensure local regulatory requirements are met.

This is likely to require temporary storage in large clean tanks without any previous PFAS usage or potential pre-existing PFAS contamination.

5. Send concentrated PFAS containing materials for disposal/destruction in accordance with local regulatory requirements.

10 Recommendations

FPA Australia’s recommendations on the selection and

use of firefighting foam are as follows:

1. The use of foams containing PFOS should be banned;

2. Existing stocks of foams containing PFOS should be removed from service and sent for high temperature incineration or equivalent destruction at an approved facility.

3. All foam manufacturers should reduce and eliminate the production of foams containing PFOA in accordance with the US EPA PFOA Stewardship Program or REACH Regulation (EU) 2017/1000.

4. Foam users should phase-out their use of C8 foams, which contain PFOS or PFOA, and transition to US EPA PFOA Stewardship Program/REACH Regulation (EU) 2017/1000 compliant C6 foams or F3 foams (providing existing safety standards are not compromised) using a holistic risk based assessment approach to select the foam most appropriate for the intended application without compromising fire life safety.

5. Regardless of whether the replacement foam under consideration is a C6 foam or F3 foam, evidence of suitability must be sought to demonstrate its ability to achieve the required firefighting performance for the specific fuel(s) stored/used, at the extremes of ambient temperature that may be encountered on site, with the aspiration level and application rates being provided by the discharge devices and



system design in place or being modified accordingly.

Evidence must also be sought to confirm that the replacement foam is compatible with the systems and equipment with which it is to be used and that the performance of these systems is not being compromised.

6. Whilst important, the environmental performance of a foam should not be used as the sole selection criteria, nor considered in isolation. Effective fire life safety and critical asset protection must also be adequately considered. Choosing the most responsible firefighting foam—the best one to protect life, property and the environment—involves selecting one that provides a combination of firefighting performance, reliability and fire life safety, balanced with minimal toxicological and adverse environmental impacts. Therefore, the following key selection criteria must all be adequately considered to ensure all realistic expectations are being met:

(a) Firefighting performance;

(b) Fire life safety;

(c) Physical properties and suitability for use on known hazards (including forceful application);

(d) Compatibility with in-depth fuels (i.e. >25 mm), system design, application method, existing delivery equipment, site conditions and approvals; and

(e) Environmental impact (including whole incident, not just foam in isolation).

7. Any proposal to change the type of foam used in a system requires careful consideration and must take fire safety and engineering factors into account. The type of foam used should not be changed without completing a detailed risk assessment review of the design, performance and operation of the system as a whole. Such design reviews should include consultation with fire system designers, foam and foam hardware suppliers/specialists, and the relevant authority having jurisdiction (AHJ).

8. Where possible, eliminate the discharge of foam during training and system testing and commissioning. Where this is not possible, use surrogate liquids or training foams. Where the discharge of foams containing

fluorosurfactants during training, testing or commissioning cannot be avoided, ensure that the discharge is contained, collected, treated and disposed of in accordance with the requirements of the relevant AHJ.

9. All firewater run off/effluent, irrespective of foam type used, should be contained and tested for regulated contaminants (including PFAS*) prior to any discharge, as it is likely to qualify as hazardous waste. It should then be treated and disposed of according to the requirements of the relevant AHJ.

*Note, significant PFAS levels may occur from non-foam related consumer products in fire incidents, even when F3 foams are being used.

11 References

1. FPA Australia Technical Advisory Committee for Special Hazard Fire Protection Systems (TAC/11/22)

2. Fire Protection Handbook – Twentieth Edition Volume II Chapter 4, Section 17 – Foam Extinguishing Agents and Systems – by Joseph L. Scheffey – Published by National Fire Protection Association Quincy, MA, USA.

3. Next Generation Fluorine-Free Firefighting Foams, paper by Rajesh R. Melkote – Engineering Director – Global Firefighting UTC Climate, Controls, and Security, Farmington CT, USA and Liangzhen Wang & Nicolas Robinet – Kidde France UTC Climate, Controls and Security, Rue Aloys Senefelder France.

4. Fact sheet on AFFF Fire Fighting Agents dated November 2013 prepared by the Fire Fighting Foam Coalition, Arlington VA, USA.

5. Do Without Per- and Poly- Fluorinated Chemicals And Prevent Their Discharge Into the Environment – published July 2009 by German Federal Environment Agency Umwelt Bundes Amt

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40. State Energy & Environmental Impact Center, NYU School of Law, PFAS Federal Legislation https://www.law.nyu.edu/centers/state-impact/press-publications/research-reports/pfas-federal-legislation

41. Transport Canada, NCR-035-2018, Exemption from paragraph 323.08(1)(a) of the Aircraft Fire Fighting at Airport and Aerodromes Standards made pursuant to section 303.08 of the Canadian Aviation Regulations https://www.tc.gc.ca/CivilAviation/Regserv/Affairs/exemptions/docs/en/3210.htm

42. Olsen G et al, 2007 – Evaluation of the Half-life (T1/2) of Elimination of Perfluorooctanesulfonate (PFOS), Perfluorohexanesulfonate (PFHxS) and Perfluorooctanoate (PFOA) from Human Serum, 2007. http://www.chem.utoronto.ca/symposium/fluoros/pdfs/TOX017Olsen.pdf

Disclaimer

The opinions expressed in this correspondence reflect those of FPA Australia. However, they are subject to change based on receipt of further information regarding the subject matter. You should interpret the technical opinion or information provided carefully and consider the context of how this opinion / information will be used in

conjunction with the requirements of regulation (state and/or federal); relevant standards, codes or specifications; certification; accreditation; manufacturer’s documentation and advice; and any other relevant requirements, instructions or guidelines. FPA Australia does not accept any responsibility or liability for the accuracy of the opinion / information provided, nor do they accept either directly or indirectly any liabilities, losses and damages arising from the use and application of this opinion / information.

Version 1 published June 2014.

Version 2 published January 2017

© Copyright 2020 Fire Protection Association Australia (FPA Australia).

Material distributed by FPA Australia is subject to copyright. Any information within this publication may not be reproduced in printed or electronic form without permission from FPA Australia.

For more information, please see www.fpaa.com.au or contact FPA Australia on 1300 731 922.



https://regenesis.com/eur/project/pfas-at-non-detect-after-a-year-following-pilot-study/

https://regenesis.com/eur/project/pfas-at-non-detect-after-a-year-following-pilot-study/

https://www1.health.gov.au/internet/main/publishing.nsf/Content/C9734ED6BE238EC0CA2581BD00052C03/$File/expert-panel-report.pdf




http://chm.pops.int/TheConvention/ConferenceoftheParties/Meetings/COP9/tabid/7521/Default.aspx



https://www.law.nyu.edu/centers/state-impact/press-publications/research-reports/pfas-federal-legislation



https://www.tc.gc.ca/CivilAviation/Regserv/Affairs/exemptions/docs/en/3210.htm

https://www.tc.gc.ca/CivilAviation/Regserv/Affairs/exemptions/docs/en/3210.htm

http://www.chem.utoronto.ca/symposium/fluoros/pdfs/TOX017Olsen.pdf

http://www.chem.utoronto.ca/symposium/fluoros/pdfs/TOX017Olsen.pdf

http://www.fpaa.com.au/



AFFF Aqueous Film Forming Foam (Fluorinated)

AHJ Authority Having Jurisdiction

AR-AFFF Alcohol Resistant Aqueous Film Forming Foam (Fluorinated)

AR-FFFP Alcohol Resistant Film Forming Fluoro-Protein Foam (Fluorinated)

AR-F3 Alcohol Resistant Fluorine Free Foam (with no fluorinated content)

AS Australian Standard

AS/NZS Australian/New Zealand Standard

BOD Biochemical Oxygen Demand

C6 Short carbon chain lower or equal to 6 carbon atoms

C6 foam Fluorinated firefighting foam where the per-fluorinated carbon chains are shorter or equal to 6 carbon atoms

C8 Long carbon chain greater or equal to 7 carbon atoms including >C8s which may breakdown to PFOA, PFOS and PFHxS (PFHxS is defined as C8 under United Nations – OECD, 2015)

C8 foam Fluorinated firefighting foam where per-fluorinated carbon chains are longer or equal to 7 carbon atoms and may breakdown to PFOS, PFOA, PFHxS.

COD Chemical Oxygen Demand

ECF Electrochemical Fluorination

EPA Environmental Protection Agency/Authority

EU European Union

FAA Federal Aviation Administration (USA)

FFFC Fire Fighting Foam Coalition

FFFP Film Forming Fluoro-Protein Foam (Fluorinated)

FM Factory Mutual Insurance Company

FP Fluoro-Protein Foam (Fluorinated)

FPA Australia Fire Protection Association Australia

F3 foam Fluorine Free Foam (with no fluorinated content)

GAC Granular Activated Carbon

ICAO International Civil Aviation Organisation

IMAP Inventory Multi-tiered Assessment and Prioritisation

IX Ion Exchange Resins

Kow Octanol-water coefficient

LRET Long-Range Environmental Transport

NEMP National Environmental Management Plan (Australia/New Zealand)

NFPA National Fire Protection Association (USA)

NICNAS National Industrial Chemicals Notification and Assessment Scheme (Australia)

OECD Organisation for Economic Cooperation and Development (United Nations)

OCRA Ozone fractionation Catalysed Reagent Addition

PAHs Polycyclic Aromatic Hydrocarbons

PBT Persistent, Bio-accumulative and Toxic

PFAS Per- and Poly-fluoroalkyl Substances

PFCs Perfluorinated and Polyfluorinated Compounds (more recently replaced by the term “PFAS”)

Appendix A – Abbreviations



PFCA Perfluorocarboxylic Acid

PFSA Perfluorosulfonic Acid

PFHxA Perfluorohexanoic Acid

PFHxS Perfluorohexane Sulfonate

PFOA Perfluorooctanoic Acid

PFOS Perfluorooctanyl Sulfonate

POPRC Persistent Organic Pollutants Review Committee (UN Stockholm Convention)

POP Persistent Organic Pollutant (POPs is the plural)

ppm parts per million (1,000,000) or mg/L

ppb parts per billion (1,000,000,000) or µg/L

mg/L 1 milligram per litre = 0.000,001 grams/litre or ppm

µg/L 1 microgram per Litre = 0.000,000,001 grams/litre or ppb

NF Nano-filtration

REACH Registration, Evaluation, Authorisation and Restriction of Chemicals (EU regulations)

RO Reverse Osmosis

SA WQ Policy

South Australia Water Quality Policy

UL Underwriters Laboratories (USA)

ULC Underwriters Laboratories of Canada

UN United Nations

US United States

US EPA United States Environmental Protection Agency

VOC Volatile Organic Compounds



This Appendix discusses the health concerns of

particular chemicals in legacy C8 foams, the phase out

of these foams and the use of replacement C6 foams.

B1 Perfluorooctanyl Sulfonate (PFOS)

PFOS is a Perfluorosulphonic acid (part of the PFAS

family) and derives from the 3M™ developed

Electrochemical Fluorination (ECF) process, (no longer

used outside China, and perhaps Russia).

The main global manufacturer of PFOS containing

foams, 3M™, voluntarily ceased global manufacture of

fluorochemicals by end 2002, but in Australia the

manufacture of 3M™ Lightwater™ AFFF and ATC™

AR-AFFF concentrates extended into 2003.

In 2004, the first 12 POPs were listed in annexes to the

Stockholm Convention. In 2009, PFOS was one of 9 new

substances added as an Annex B Restricted substance

in accordance with the Stockholm Convention with the

expectation that every four years progress on its

elimination is reported. It should be noted that

Australia’s National Implementation Plan – Stockholm

Convention on Persistent Organic Pollutants (dated

July 2006) was published by the Commonwealth

Department of the Environment prior to the addition

of PFOS as a POP.

Australia is yet to ratify this addition of PFOS as an

Annex B Restricted substance and update the National

Implementation Plan to reflect this. Australia is

considering ratification of PFOS as a POP but must go

through a domestic treaty process for which the

Commonwealth Department of the Environment and

Energy is responsible. FPA Australia considers that the

Australian Government should ratify PFOS as a POP in

accordance with the Stockholm Convention urgently to

provide clarity for foam users and protection for our

environment.

The Stockholm Convention’s goal is to reduce and

ultimately eliminate production and use of PFOS and

encourages:

Phase out of PFOS use when suitable alternative substances or methods are available;

Producers or users of PFOS to develop and implement an action plan for elimination; and

PFOS producers or users, within their capabilities, to promote research on development of safe alternative substances to reduce human health risks and environmental implications.

The European Union (EU) has prohibited the marketing

and use of PFOS since 27 June 2008. Subsequently,

PFOS was banned from use in 28 European countries in

2011, requiring high temperature incineration (above

1,100°C) to destroy it. New Zealand followed by

banning it in 2011 and Canada followed in 2013.

As PFOS is listed as a Persistent Organic Pollutant under

the United Nations (UN) Stockholm Convention,

FPA Australia recommends that any fluorinated

firefighting foam containing PFOS and/or its related

chemicals, including PFHxS, should be immediately

removed from service and sent to an authorised

regulated waste facility for disposal.

B2 Perfluorooctanoic Acid (PFOA)

PFOA is a Perfluorocarboxylic acid (PFCA) (part of the

PFAS family) and has been accepted for listing as a POP

by the UN Stockholm Convention POPRC.

Concerns about PFOA’s persistence, detection in

human blood and effects in animal studies has led to

further scientific research. This research has shown

Appendix B – Health concerns and phase out of

legacy C8 foams and the use of replacement C6

foams



that C8 fluorochemicals have larger more complex

precursor molecules, which are more likely to

breakdown to C8 endpoint substances (PFOS, PFOA

and PFHxS) that are persistent, toxic, bio-accumulative

and remain in mammalian organisms for long periods

of time. Research indicates that C8 fluorochemicals

have half-lives in humans typically averaging 5.4 years

for PFOS, 8.5 years for PFHxS, and 3.5 years for PFOA.

In comparison, the main short-chain C6 foam

breakdown product PFHxA has an average human half-

life of just 32 days.

PFOA was mainly used as a polymerization aid in the

manufacture of several types of fluoropolymers. The

ECF that produced PFOS from C8 precursors also

generated some unavoidable PFOA as a by-product of

the manufacturing process (generally at a ppm level),

and from C8 precursors. Similarly, trace amounts of

PFOA (but not PFOS) can be found from precursors and

in C8 fluorotelomers. These fluoropolymers were used

in a wide variety of industrial and consumer products,

including domestic cookware, but not in firefighting

applications.

In 2006, the US EPA and eight global fluorotelomer and

fluoropolymer manufacturers launched a voluntary

PFOA Stewardship Program working towards

elimination of PFOA and its precursor chemicals from

their production processes, waste streams and finished

products by the end of 2015, which was achieved.

All major fluorotelomer manufacturers who were part of

the US EPA PFOA stewardship program have virtually

eliminated PFOA (down to ppb levels) from

fluorotelomer surfactants as they transitioned to

environmentally more benign high purity (≥98.5%)

short-chain C6 alternatives which are now being used in

firefighting foam concentrates by all main

manufacturers (outside China and perhaps Russia). The

remaining percentage consists predominantly of C4

fluorosurfactants, improving environmental outcomes

and complying with both the US EPA PFOA Stewardship

Program and the REACH Regulation (EU) 2017/1000

requirements for PFOA.

It is interesting to note that the French Food Safety Agency

and Norwegian Institute of Public Health have evaluated

the potential human health risks related to the residual

presence of PFOA in non-stick coatings for cookware,

concluding that the consumer health risk is negligible.

B3 C6 fluorotelomers

Scientific research has shown that C6 foams are

environmentally more benign than those using C8

fluorochemicals, including PFOS and PFOA, and are

widely considered safe for continued use.

C6 fluorotelomer surfactants meeting the US EPA PFOA

Stewardship Program and the REACH Regulation (EU)

2017/1000 do not have the same adverse

environmental profile as PFOS, PFHxS, PFOA or PFOA

precursors. Scientific research indicates that they are

not bio-accumulative, not carcinogenic, not genotoxic,

not endocrine disruptors, not developmental toxins

nor mutagenic and they exhibit low toxicity to humans

and aquatic environments.

The Australian Department of Health, Expert PFAS

health panel concluded in its May 2018 advice that:

“There is no current evidence that supports a large

impact on an individual’s health” from C6

fluorotelomers and “In particular, there is no

current evidence that suggests an increase in

overall cancer risk” from C6 PFAS use.

This health report confirms "Differences between

those with the highest and lowest exposures are

generally small, with the highest groups generally

still being within the normal ranges for the whole

population. There is mostly limited or no evidence

for an association with human disease

accompanying these observed differences.”

It concludes, “Our advice to the Minister in regards

to public health is that the evidence does not

support any specific biochemical or disease

screening, or health interventions, for highly

exposed groups, except for research purposes."

US EPA Stewardship Program and REACH Regulation

(EU) 2017/1000 compliant C6 fluorotelomer

surfactant-based foams:

Do not break down to PFOS, PFOA or chemicals currently listed or suspected of being POPs or



persistent, bio-accumulative and toxic (PBT) substances;

Although persistent, are not made with chemicals currently considered to be bio-accumulative, nor toxic by environmental authorities; and

Are not listed by the Stockholm Convention or European Chemicals Agency (2016) list of substances of high or very high concern (VHC).

Importantly, C6 foams retain fast, effective, reliable

and efficient firefighting performance, in most cases

equivalent to C8 foams, without increased

fluorochemical content. Equivalency has been verified

using the MilSpec foam test standard and UL listings.

selection and use of firefighting foams - fpa a

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